Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health 

REVIEW OF THE 

JOSLYN MANUFACTURING AND SUPPLY COMPANY 

PETITION EVALUATION REPORT FOR 

SPECIAL EXPOSURE COHORT (SEC) PETITION 00200 

Contract No. 200-2009-28555 

SCA-TR-SEC2013-0069 

Prepared by 

John Mauro 

Bill Thurber 

Stephen Ostrow 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

March 2013 

Disclaimer

This document is made available in accordance with the unanimous desire of the Advisory Board on 

Radiation and Worker Health (ABRWH) to maintain all possible openness in its deliberations. However, 

the ABRWH and its contractor, SC&A, caution the reader that at the time of its release, this report is predecisional and has not been reviewed by the Board for factual accuracy or applicability within the 

requirements of 42 CFR 82. This implies that once reviewed by the ABRWH, the Board’s position may 

differ from the report’s conclusions. Thus, the reader should be cautioned that this report is for 

information only and that premature interpretations regarding its conclusions are unwarranted. 
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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

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Document No. 

SCA-TR-SEC2013-0069 

Effective Date: 

 Draft – March 28, 2013 

S. Cohen & Associates: 

Technical Support for the Advisory Board on 

Radiation and Worker Health Review of NIOSH 

Dose Reconstruction Program Revision No: 

0 – Draft 

Review of the Joslyn Manufacturing and Supply 

Company Petition Evaluation Report for Special 

Exposure Cohort (SEC) Petition 00200 

Page 2 of 39 

Task Manager: 

_____________________ Date: ____________ 

John Mauro, PhD, CHP 

Supersedes: 

N/A 

Project Manager: 

_____________________ Date: ____________ 

John Stiver, MS, CHP 

Reviewers: 

 Arjun Makhijani 

 John Stiver 

Record of Revisions 

Revision 

Number 

Effective 

Date Description of Revision 

0 (Draft) 03/28/2013 Initial issue 
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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

CONTENTS 

Abbreviations and Acronyms ..........................................................................................................5 

Executive Summary.........................................................................................................................7 

1.0 Introduction........................................................................................................................10 

1.1 Scope and Purpose of SEC Review .......................................................................10 

1.2 Technical Approach and Review Criteria..............................................................10 

1.3 Background Information........................................................................................11 

2.0 Review of Methods for Reconstructing Internal Doses.....................................................14 

2.1 Reconstruction of Internal Doses – Applicability of TBD-6000...........................14 

2.2 Available Joslyn Data for Internal Monitoring......................................................18 

2.3 Uranium Airborne Levels......................................................................................19 

2.4 Evaluation of Bounding Residual Period Internal Doses ......................................20 

2.5 Methods for Bounding Operational Period Internal Dose at Joslyn......................20 

2.6

............................................25 

Data Adequacy Concerns: Uranium Waste Burn Pits at Joslyn 

Manufacturing Site, Chip Fires, and Floor Sweeping

2.6.1 .....................................................................................................25 Burn Pits

2.6.2 ...................................................................................................27 Chip Fires

2.6.3 ....................................................................................................28 Sweeping

3.0 Review of Methods for Reconstructing External Doses....................................................29 

3.1 Evaluation of Bounding Process-Related External Doses.....................................29 

3.2 Methods for Bounding Operational Period External Dose at Joslyn.....................30 

4.0 SC&A Review of Joslyn Petition Evaluation Report Worker Interviews.........................31 

5.0 Use of Surrogate Data........................................................................................................33 

6.0 References..........................................................................................................................37 

Attachment A: Residual Radioactivity Evaluations for Individual Facilities...............................39 
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LIST OF TABLES 

Table 2-1. Comparison of TBD-6000 and Joslyn Job Descriptions............................................ 17 

Table 2-2. Comparison of MDCs and Calculated Centerless Grinder BZ 

“Non-Detect” Samples................................................................................................ 19 

Table 2-3. Reconstruction of Table 7-1 of the Petition Evaluation Report ................................. 22 

Table 2-4. Reconstruction of Table 7-2 of the Petition Evaluation Report Comparing 

Joslyn Air Concentrations from Centerless Grinding to TBD-6000 Defaults............ 23 

Table 2-5. Atmospheric Concentrations of Uranium at Hanford Melt Plant Outdoor 

Burning Operations..................................................................................................... 27 

Table 5-1. Comparison of Breathing Zone Samples during Rolling ........................................... 33 

Table 5-2. Comparison of Air Samples during Machining.......................................................... 33 
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ABBREVIATIONS AND ACRONYMS 

Advisory Board, Advisory Board on Radiation and Worker Health 

ABRWH, or Board 

AEC U.S. Atomic Energy Commission 

AM arithmetic mean 

AWE Atomic Weapons Employer 

bgs below ground surface 

BZ breathing zone 

CDC Centers for Disease Control and Prevention 

CFR Code of Federal Regulations

Ci Curie 

cm2 square centimeter 

cpm counts per minute 

DOE Department of Energy 

DOL Department of Labor 

dpm (α)/m2 disintegrations per minute (alpha) per square meter 

dpm disintegrations per minute 

DWA daily weighted average 

DWE daily weighted exposure 

EEOICPA Energy Employees Occupational Illness Compensation Program Act of 

2000 

ER Evaluation Report 

ERDA Energy Research and Development Administration 

FUSRAP Formerly Utilized Sites Remedial Action Program 

g gram 

GA general area 

GM Geometric Mean 

GSD Geometric Standard Deviation 

HASL Health and Safety Laboratory 

IREP Interactive RadioEpidemiological Program 

m3 cubic meter 

MDC minimum detectable concentration 

MED Manhattan Engineering District 
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mR milli-Roentgen 

mrem/yr millirem per year 

m/s meter per second 

NIOSH National Institute for Occupational Safety and Health 

ORAUT Oak Ridge Associated Universities Team 

ORNL Oak Ridge National Laboratory 

pCi picoCurie 

R Roentgen 

SC&A S. Cohen & Associates 

SEC Special Exposure Cohort 

SQRT square root 

SRDB Site Research Database 

SRQD Site Research Query Database 

TBD Technical Basis Document 

TIB Technical Information Bulletin 

TWA time-weighted average 

μg/cm3 microgram per cubic meter 
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EXECUTIVE SUMMARY 

During a meeting of the Advisory Board on Radiation and Worker Health (the Board) held in 

Oak Ridge, Tennessee, on December 10–12, 2012, SC&A was directed to perform a review of 

the NIOSH Evaluation Report (ER) for Joslyn Manufacturing and Supply Company Special 

Exposure Cohort (SEC) Petition 00200 (NIOSH 2012a). The petition was received on March 15, 

2012, qualified on May 10, 2012, and the ER was issued on December 3, 2012. 

The petition called for adding the worker class, defined as: 

All employees who worked in any area of the Joslyn Manufacturing and Supply 

Company in Fort Wayne, Indiana, from 1944 through 1952.

NIOSH redefined the class as follows: 

All employees who worked in any area of the Joslyn Manufacturing and Supply 

Company in Fort Wayne, Indiana, from March 1, 1943 through December 31, 

1952.

 

In its evaluation, NIOSH recommended the following class be added to the SEC, including 

certain qualifications, as follows: 

All Atomic Weapons Employees who worked in any buildings/area owned by the 

Joslyn Manufacturing and Supply Co. (or a subsequent owner) in Fort Wayne, 

Indiana, from March 1, 1943 through December 31, 1947, for a number of work 

days aggregating at least 250 work days, occurring either solely under this 

employment or in combination with work days within the parameters established 

for one or more other classes of employees included in the Special Exposure 

Cohort. ....

However, NIOSH has identified sufficient information and air monitoring data 

that can be assessed using existing dose reconstruction methods defined in 

Battelle-TBD-6000 to support bounding internal dose for the period from January 

1, 1948 through December 31, 1952. 

In its ER, NIOSH also makes the following statement: 

Although NIOSH found that it is not possible to completely reconstruct radiation 

doses for the proposed class, NIOSH intends to use any internal and external 

monitoring data that may become available for an individual claim (and that can 

be interpreted using existing NIOSH dose reconstruction processes or 

procedures). Therefore, dose reconstructions for individuals employed at Joslyn 

Manufacturing during the period from March 1, 1943 through December 31, 

1947, but who do not qualify for inclusion in the SEC, may be performed using 

these data as appropriate. 
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This is an important qualifying statement, especially for workers who were present at Joslyn 

during the covered period, but are not within the cohort because they do not have one or more of 

the cancers covered by the SEC. The implications are that every effort will be made by NIOSH 

to reconstruct doses to all workers not within the cohort. 

SC&A examined the petition, the NIOSH ER, and a number of supporting documents, primarily 

to assist the Board in assessing the degree to which NIOSH can “estimate radiation doses with 

sufficient accuracy” for those workers not covered by the class. NIOSH did not prepare a site 

profile for this site because of the limited site-specific data, which is the basis for the SEC, and 

the fact that data provided in TBD-6000 and other documents cited in the petition ER can be 

used to reconstruct worker doses for those time periods and claimants not covered by the SEC. 

This report presents the results of SC&A’s investigations with regard to this matter. Our 

findings are summarized as follows: 

Finding 1: The units of measure for the data from Klevin (1952) in Table 6-1 are cited as 

pCi/m3

, but the presented information is based on dpm/m3. 

Finding 2: The units of measure in Table 6-2 should be dpm/m3, not pCi/m3. 

Finding 3: NIOSH should document the basis for assuming that 1948 is the starting date for 

the site surveys upon which TBD-6000 is based. The 1948 date needs to be affirmatively 

established in order to ensure that the TBD-6000 data are claimant favorable. 

Finding 4: Table 7-1 needs to be corrected to assure that comparable units are used 

throughout, and that 1952 air concentrations from TBD-6000 are based on 2,200 work hours 

per year. 

Finding 5: Typographical and calculational errors in Table 7-2 should be corrected. 

Finding 6: The NIOSH approach for reconstructing internal doses due to metal-working 

operations at Joslyn for 1948 through 1952 appears reasonable for routine exposures. 

However, we have concerns that the exposure matrix does not adequately describe how the 

dose reconstruction methods in TBD-6000 are to be applied. In addition, as developed further 

under Finding 8, we have concerns regarding the degree to which the surrogate values in 

TBD-6000 adequately account for exposures associated with outdoor uranium pit burning and 

with incidents such as uranium chip fires. 

Finding 7: To address uncertainty as to whether air concentrations are dependent upon 

production rates, NIOSH should consider using the 95th percentile values from TBD-6000 to 

reconstruct doses at Joslyn.

Finding 8: Though of short duration, the airborne uranium dust levels associated with 

uranium open pit burning and associated activities, such as shoveling the burn residue into 

containers, could contribute significantly to annual intakes of uranium. NIOSH needs to 

evaluate the degree to which outdoor open pit burning of uranium shards renders TBD-6000 

incomplete as a surrogate dataset for Atomic Weapons Employer (AWE) facilities with limited 
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NOTICE:

bioassay and air sampling data. NIOSH should do the same for uranium chip fires that may 

have occurred in the machining or scrap storage areas. A third area of concern is that there 

are no data for the frequent sweeping activities that likely generated considerable 

resuspension of uranium dust. The present intake matrix is incomplete in all three respects. 

Finding 9: It would strengthen the report if the basis for the 90% coverage of the uranium 

source term was documented.

Finding 10: SC&A does not agree with some of the assumptions proposed by NIOSH in 

Section 7.3.1 of the ER. SC&A suggests that NIOSH consider prorating the dose values in 

Table 6-4 based on actual working time, such as days per month. At a minimum, the NIOSH 

approach appears to underestimate external exposure in 1948. In addition, there is no need to 

differentiate between rolling and machining operations, since the doses are the same. 

However, there is one caveat—the units of measure for the data listed in Table 6-4 as Metal 

Whole Body Dose should be mrem/yr, not mR/yr. This is an important consideration when 

converting whole-body dose to organ dose. 

Finding 11: NIOSH should document the sources of information they propose to use 

regarding the relative radiological hazard from thorium. 

These findings are described and discussed in detail in the main body of this report. Our primary 

concerns are that (1) NIOSH has not provided explicit instructions for performing dose 

reconstructions for the time period not covered by the SEC, (2) the possibility that open pit 

burning of uranium shards could contribute significantly to internal exposures to some workers, 

and (3) intakes from incidents such as uranium chip fires known to be frequent in the era under 

consideration were mentioned, but not quantitatively evaluated in the ER or in TBD-6000. The 

open pit burning and uranium chip issues are especially important, because they bear on the 

ability of using TBD-6000 as a surrogate for AWE facilities with limited bioassay and air 

sampling data. 
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1.0 INTRODUCTION 

1.1 SCOPE AND PURPOSE OF SEC REVIEW 

Based on recommendations by the National Institute for Occupational Safety and Health 

(NIOSH), a Special Exposure Cohort (SEC) was granted for Joslyn Manufacturing and Supply 

Company (Joslyn) for the time period from March 1, 1943, through December 31, 1947, because 

internal doses could not be reconstructed with sufficient accuracy. However, NIOSH also 

concluded that sufficient data and other information, primarily available from TBD-6000, can be 

used to reconstruct all doses from January 1, 1948, through December 31, 1952, which 

constitutes the remainder of the class evaluated by NIOSH. Therefore, the scope of this review 

is to evaluate the degree to which exposure to workers not covered by the SEC can be 

reconstructed, and the methods, data, and assumptions to be employed in those dose 

reconstructions. 

In the course of its assessment, SC&A reviewed selected documents that were considered 

relevant to the petition, including the SEC Petition Evaluation Report (ER) and its supporting 

documents as provided in the NIOSH Site Research Query Database (SRQD) and notes 

compiled during worker interviews. 

The purpose of this review is to provide the Advisory Board on Radiation and Worker Health 

(Advisory Board or Board) with an independent assessment of issues and concerns that surround 

the petition. Findings identified in SC&A’s review are intended help the Board judge the 

feasibility of, and methods used to perform, dose reconstructions for Joslyn workers. 

1.2 TECHNICAL APPROACH AND REVIEW CRITERIA 

The approach used by SC&A to perform this review follows the protocols described in the draft 

reports prepared by SC&A entitled Board Procedures for Review of Special Exposure Cohort 

Petitions and Petition Evaluation Reports, Revision 1 (SC&A 2006b), and the Report to the 

Working Group on Special Exposure Cohort Petition Review (SC&A 2006a). The latter is a set 

of draft guidelines prepared by a Board-designated Work Group for evaluation of SEC petitions 

performed by NIOSH and the Board. The former is a set of draft procedures prepared by SC&A 

and approved by the Board for use by SC&A on an interim basis (ABRWH 2006, pg. 132). The 

procedures are designed to help ensure compliance with Title 42, Part 83, of the Code of Federal 

Regulations (42 CFR 83) and implement the guidelines provided in the report of the Work 

Group. 

Key review criteria identified in the report of the Work Group include the following; the 

individual criteria have differing degrees of applicability, depending on the details of a particular 

SEC petition and ER: 

 Timeliness 

 Fairness 

 Understandability 
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 Consistency 

 Credibility and validity of datasets, including pedigree of the data, methods used to 

acquire the data, relationship to other sources of information, and internal consistency 

 Representativeness and completeness of the exposure data with respect to the area of the 

facility, the time period of exposure, the types of workers, and processes covered by the 

data 

The Work Group guidelines also recommend that NIOSH include in its SEC evaluation a 

demonstration that it is feasible to reconstruct individual doses for the cohort, including sample 

dose reconstructions. 

SC&A’s implementation of the SEC review process includes the following steps: 

(1) Conduct a critical review of the petition and relevant reports, documents, and data that 

are enclosed and/or referenced in the petition/reports. 

(2) Identify additional issues/concerns that emerged from SC&A’s document review, which 

are independent of those stated in the petition. 

(3) As part of the SEC review, develop a technical position for issues identified in the 

petition, as well as SC&A’s independent findings. 

SC&A’s report with its findings will subsequently undergo a multi-step issues resolution 

process. Resolution includes a transparent review and discussion of draft findings with members 

of the Board’s Work Group, petitioners, claimants, and interested members of the public. This 

resolution process is intended to ensure that each finding is evaluated on its technical basis in a 

scientifically sound and claimant-favorable manner. 

In the past, SC&A’s review of petition ERs included site visits, which included interviews with 

workers and other site experts, and data capture visits to obtain documents that might further our 

understanding of the dose reconstruction issues associated with a facility. In this case, NIOSH 

has performed such site visits, which included SC&A participation, and we do not recommend 

any additional site visits at this time. However, the need for additional site visits and data 

capture efforts might emerge during the issues resolution process. 

1.3 BACKGROUND INFORMATION 

Section 5 of the petition ER presents a detailed description of the operations that took place at 

Joslyn and the associated exposures. In summary, Joslyn Manufacturing, located in Fort Wayne, 

Indiana, was a steel mill that: 

...performed tempering, hot rolling, quenching, straightening, cooling, grinding, 

waste burning, and abrasive cutting of natural uranium billets into metal rods for 

use in Hanford site nuclear reactors. Joslyn Manufacturing was instrumental in 

developing the procedures for rolling uranium metal rods. Joslyn also performed 

rolling operations after 1949 for the Chalk River reactor fuel assemblies. 
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At the time of these Atomic Weapons Employee (AWE) operations, 25–75 out of a total staff of 

about 100 to 200 workers were employed in AWE operations. Apparently, the AWE operations 

began in June 1943 and continued well into 1951. In addition, thorium operations, which 

included rod straightening and rolling operations and centerless grinding, took place in 1946 and 

1947, consistent with the affidavit submitted as part of the SEC petition. 

During the early years, facilities like Joslyn performed the initial work that helped to establish 

the uranium and thorium metal handling technologies and techniques that were implemented on 

a large scale in the late 1940s and early 1950s at many AWE facilities and then throughout the 

weapons complex. In addition, it was the experience gained by Joslyn and other facilities, such 

as Simonds Saw, where our understanding of the health risks associated with uranium and 

thorium and the development of radiation protection programs began. Hence, it is 

understandable that it was not possible to reconstruct worker exposures during the early years of 

AWE operations at Joslyn. The fundamental concern of this report is whether sufficient 

operational data and experience became available in the latter years of the 1940s, such that doses 

to all workers could be reconstructed in a scientifically sound and claimant-favorable manner for 

the 1948–1952 time period. 

Section 5.2 of the petition ER explains that the primary source of internal exposure was the 

inhalation and, to a lesser extent, the ingestion of uranium oxide dust produced during the 

handling of uranium. The uranium burning pits (outdoors) were another source of internal 

exposure, as was the handling of thorium. It appears that the uranium handled at Joslyn was 

entirely natural uranium; i.e., Joslyn did not handle enriched or recycled uranium. This is a 

reasonable assumption, given the time periods that the AWE work was performed. However, the 

petition evaluation report would benefit from a discussion of this issue. 

External exposures at Joslyn included the conventional pathways; i.e., working in close 

proximity to large quantities of uranium metal rods and billets, standing on contaminated 

surfaces, and submersion in airborne clouds of uranium dust. 

There was also the potential for internal and external exposure to relatively small amounts of 

thorium and the possibility of medical x-rays as a condition of employment. Neutron exposures 

were unlikely, because there was no enriched uranium (i.e., no fission neutrons) and no uranium 

in the form of nitrates or fluorides, which would have had the potential to produce alpha/n 

reactions. 

The petition ER also explains that no bioassay or whole-body count data were collected for 

Joslyn workers, but a limited amount of air sampling data and surface smear data related to 

uranium operations were recovered and summarized in the petition ER. The implications are 

that if internal doses are to be reconstructed for Joslyn workers that might have been exposed to 

either uranium or thorium, surrogate data would be required, with adequate justification. 

In addition, there are no external exposure personnel monitoring data for Joslyn workers, but 

information is available describing the types and quantities of uranium and thorium handled at 

Joslyn. Hence, in principle, bounding estimates of the external radiation fields experienced by 

workers could be developed using source term data. As will be seen, there was also the potential 
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NOTICE:

for exposure to medical x-ray examinations as a condition of employment. Specifically, 

Section 7.3.3 of the SEC ER indicates that medical x-rays were required as a condition of 

employment, but that it was not possible to determine whether the examinations were performed 

onsite or offsite, stating the following: 

NIOSH has no further data regarding if medical X-ray examinations may have been 

performed onsite versus offsite. Per ORAUT-OTIB-0079, Guidance on Assigning 

Occupational X-ray Dose Under EEOICPA for X-rays Administered Off Site [ORAUT 

2011], NIOSH has determined that it is applicable to reconstruct occupational medical 

X-ray exposures for Joslyn Manufacturing and Supply Co. workers during the period 

from March 1, 1943 through December 31, 1952. 

The implications of this statement are that reconstruction of external doses at Joslyn should 

include medical x-rays.
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2.0 REVIEW OF METHODS FOR RECONSTRUCTING 

INTERNAL DOSES 

For the time periods not covered by the SEC, the petition ER uses TBD-6000 protocols to 

reconstruct internal exposures. These protocols are based on a compendium of data reported 

primarily by Harris and Kingsley (1959). Accordingly, this section of our report focuses on two 

issues; (1) were the operations at Joslyn beginning in 1948 (i.e., the period not covered by the 

SEC) understood well enough, and (2) are there sufficient confirmatory data, such that 

judgments could be made that TBD-6000 protocols can be used as a surrogate for the data that 

are lacking at Joslyn, and if so, does the ER make use of those protocols in a manner that is 

scientifically sound and claimant favorable? 

2.1 RECONSTRUCTION OF INTERNAL DOSES – APPLICABILITY OF TBD-6000 

This section addresses the applicability of TBD-6000 data to Joslyn during the period January 1, 

1948, through December 31, 1952. Section 5.1 of the petition ER describes the uranium 

fabrication operations, noting that: 

Joslyn Manufacturing and Supply Company, also known as Joslyn Stainless Steel 

Company, Fort Wayne Steel Corporation, and Slater Steel, performed tempering, 

hot rolling, quenching, straightening, cooling, grinding, waste burning, and 

abrasive cutting of natural uranium billets into metal rods for use in Hanford site 

nuclear reactors. Joslyn Manufacturing was instrumental in developing the 

procedures for rolling uranium metal rods. Joslyn also performed rolling 

operations after 1949 for the Chalk River reactor fuel assemblies. 

Natural uranium billets were received by rail at Joslyn Manufacturing, unloaded 

by an overhead crane onto carts, and stored in a storage area. The billets were 

taken, as needed, from the storage area to the tempering area, pre-heated in one 

of eight small natural-gas-atmosphere electric furnaces to a specified 

temperature, and moved to the rolling mills (an 18-inch roughing stand, 12-inch 

intermediate mill, and a 9-inch finishing mill were used) where passes occurred 

(Army Corps, 2005, PDF pp. 6–7). Time was allowed for the rolls to cool 

between passes in order to prevent the metal from exceeding a specified 

temperature. 

The grinding process was carried out in two widely separated parts of a large 

shed. The first operation consisted of grinding uranium rods. This process was 

carried out in a small shed constructed inside a larger shed. The fumes and dust 

from this smaller shed were vented into the atmosphere of the larger shed. The 

second operation was a rough cut on the uranium rods inside of the smaller shed. 

The rods were cropped and moved to the threading area, where they were milled 

and machined to contract specifications (Army Corps, 2005, PDF p. 7). 

SC&A has reviewed the available documentation and finds that this description generally reflects 

uranium operations at Joslyn. However, it does not appear that centerless grinding was 
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conducted in the 1948–1949 period. Piccot (1949) describes operations after completion of 

rolling, noting that: 

After rolling the rods were placed on a roll conveyor, and moved for a distance of 

approximately 80’ outside the building where they were stamped for 

identification. After stamping the rods were moved from the conveyor and placed 

over a cooling pit on cross bars for 10 minutes, quenched in a water tank and 

allowed to cool and removed by jeep to the next operation or to the freight car for 

shipping. 

Piccot describes the next operations as follows: 

After quenching, the rods are bundled (6 to a bundle) and are carried to the cutoff machine, called cutamatic, which is located in the cold finishing department. 

The rough ends were cropped while a heavy flow of coolant was used over the 

cutting tool and the rod end to minimize sparking hazard. 

The treading was done on a Pratt & Whitney 15” lathe with a continuous flow of 

coolant over the cutting point. 

The added information from the contemporaneous report of Piccot (1949) indicates that: 

 Some of the operations were conducted outdoors 

 Cutting and machining operations were accomplished with heavy coolant flow 

 Transfer of the uranium shapes was typically done via cranes, overhead trolleys, and roll 

conveyors, which would result in lower dust generation than if the uranium shapes had 

been dragged across the floor 

All of these factors would contribute to lower dust generation during product handling. 

Table 6-2 of the ER identifies 19 job descriptions or work areas for which daily weighted 

average (DWA) exposures were measured by the Health and Safety Laboratory (HASL) during a 

1952 survey of air concentrations at Joslyn (Klevin 1952). 

TBD-6000 characterizes both uranium rolling and uranium machining based on data collected by 

Harris and Kingsley (1959) at unspecified Atomic Energy Commission (AEC) sites. An excerpt 

from the section on Rolling in Harris and Kingsley (1959) is included below: 

The usual sequence of operations involved in the process of rolling is as follows: 

(1) A uranium billet or slab is heated to a suitable temperature in a furnace 

(normally about 1170° F). Gas-fired, lead-bath, salt-bath, and induction 

furnaces have been used. The choice of a furnace can be very important 

from the standpoint of worker health and dust-control ventilation. This will 

be discussed more fully below. 
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(2) The billet is removed from the furnace and conveyed to a roughing roll for 

lengthening into shapes (rods or slabs) or rough dimension. Several passes 

are usually made through the roughing roll. 

(3) The roughed shape is then passed through one or more finishing rolls, either 

manually or automatically. 

(4) The finished section is dragged or conveyed to shears for cutting into the 

desired number of sections for handling and further processing. 

(5) The rods or strips are then dragged or conveyed to another area where they 

are quenched or air cooled and stamped for identification and 

accountability. 

(6) After stamping, they may be descaled and straightened, bundled, weighed, 

recorded, packed, stored, and shipped. 

All these operations may be performed manually, or many of them can be done 

automatically. 

Most of these operations are potentially capable of releasing large quantities of 

uranium dust to the plant atmosphere. This is due to the rapid surface oxidation 

of uranium at the temperatures used in heating and rolling (about 1200° F). The 

oxide scale thus formed is readily removed during any handling. This oxidation is 

not confined to the heating and rolling operations; on the contrary, the oxide 

forms continuously and spontaneously flakes off the metal at temperatures above 

600° F. Any vigorous working of the metal produces a temperature rise which 

may initiate oxide formation, flaking, and subsequent air-borne contamination. 

As indicated above, the type of furnace used can strongly influence the rate of 

oxide formation. When a gas-fired, air-atmosphere furnace is used, there is so 

much oxidation in the furnace during heating that large quantities of uranium are 

deposited on the furnace floor and therefore lost for further processing. In 

addition, during removal of the billet from the furnace, conveyance to the rolls 

and introduction to the rolls, oxidation continues. Needless to say, this oxide 

scale tends to contaminate the air. Thus, ventilation and other control methods 

are necessary to reduce air-borne concentrations to satisfactory levels. These 

will be discussed below.

It is clear that the rolling process, as described by Harris and Kingsley (1959), is very similar to 

the process as practiced at Joslyn. Unlike Harris and Kingsley, Piccot (1949) makes no mention 

of dragging the product across the floor. 

Table 2-1 compares the job descriptions evaluated at Joslyn by HASL (Klevin 1952) with those 

included from Harris and Kingsley (1959) in TBD-6000. 
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Table 2-1. Comparison of TBD-6000 and Joslyn Job Descriptions 

Job Description Included in Joslyn Survey 

(Klevin 1952) 

Included in 

TBD-6000 Comments 

18" Rough Roll East Yes Yes TBD-6000 Table 7.3 

18" Rough Roll West Yes Yes TBD-6000 Table 7.3 

Roller Foreman Yes No TBD-6000 Table 7.3 (Supervisor) 

Ass't Foreman Yes No TBD-6000 Table 7.3 (Supervisor) 

Furnace Heaters Yes Yes TBD-6000 Table 7.3 (Gas-fired furnace) 

Recorder Yes No TBD-6000 Table 7.3 (Laborer) 

12" Rough Roll East Yes Yes TBD-6000 Table 7.3 

12" Rough Roll West Yes Yes TBD-6000 Table 7.3 

Drag Down (Billet) Yes No TBD-6000 Table 7.3 (Laborer) 

9" Finishing Roll East Yes Yes TBD-6000 Table 7.3 

9" Finishing Roll West Yes Yes TBD-6000 Table 7.3 

Quench Tank Yes Yes TBD-6000 Table 7.3 (Spray cooling) 

Draggers Yes Yes TBD-6000 Table 7.3 

Rod Stamper Yes Yes TBD-6000 Table 7.3 

Rod Bundler Yes No TBD-6000 Table 7.3 (Laborer) 

Lathe Operator Yes Yes TBD-6000 Table 7.5 

Centerless Grinder Yes Yes TBD-6000 Table 7.5 

Grinder (portable) Yes Yes TBD-6000 Table 7.5 

Cutomatic Yes No TBD-6000 Table 7.5 (Operator) 

It can be seen from this table that nearly all of the same jobs are included in both sources, 

indicating that scope of the job coverage in TBD-6000 adequately embraces the jobs performed 

at Joslyn. It should be remembered that TBD-6000 does not use the individual job data, such as 

the rod stamper or quench tank operator, but rather considers all of the rolling-related jobs for 

which data are available and selects from that group the job with the highest dust exposure. This 

exposure defines the generic operator for rolling. As shown in Table 7.3 of TBD-6000, the 

highest exposures are attributed to the roughing roll operator, whose exposure then defines the 

generic rolling operator. In the case of machining operations, the generic operator is defined by 

exposures to the centerless grinder operator (see Table 7.5 of TBD-6000). TBD-6000 also 

provides a methodology for estimating exposures to generic supervisors, laborers, and clerical 

staff. These estimates can be used where specific job descriptions are not listed in TBD-6000; 

for example, a rod bundler can be assumed to be a laborer. For many of the rolling-related job 

descriptions in Harris and Kingsley (1959), the authors present data for manual operations with 

no controls; manual operations with controls, such as salt-bath heating; and automated 

operations. The rolling operation values for use in TBD-6000 were conservatively selected as 

the manual with no controls data. Similarly, for the machining operations, Harris and Kingsley 

include data both with and without ventilation, but conservatively, only the latter were included 

in TBD-6000. 

In terms of coverage of comparable operations, data in TBD-6000 effectively capture the 

operations at Joslyn. The specific data selected from the source document (Harris and Kingsley 

1959) are conservative choices and thus can be used to make bounding dose calculations as 

required by 42 CFR §83.13(c)(1) for the period in which those measurements were taken. 

However, as discussed in Section 2.5 below, NIOSH has yet to show that the Harris and 

Kingsley data are representative of the operational period at Joslyn from January 1, 1948, 
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through December 31, 1952. In addition, as discussed in Section 2.6 below, uranium pit burning 

is not explicitly addressed in TBD-6000, and there is a need to demonstrate that the default data 

in TBD-6000 bound the contribution to exposures associated with uranium open pit burning. 

 

2.2 AVAILABLE JOSLYN DATA FOR INTERNAL MONITORING 

Table 6-1 of the ER summarizes the available site-specific data on air concentrations at Joslyn. 

This section presents a review of that data. However, as a preface to this review, we remind the 

reader that the interview record of July 2012 indicates that workers swept up scale and dust every 

half hour, which could generate considerable dust for short periods of time (not unlike outdoor 

uranium pit burning). There are no measurements for air dust concentrations due to this 

important activity. This is an important limitation in the Joslyn air sampling data. It is also 

important to note that it is not apparent that TBD-6000 and its supporting documentation provide 

quantitative dust data that could apply to the frequent sweeping operations at Joslyn. Harris and 

Kinsley do note the importance of housekeeping to dust control, but do not provide data that 

would be applicable to manual sweeping (pp. 92–93). The issue of uranium dust arising from 

chip fires also needs to be addressed. See Section 2.6 below for further elaboration of these 

issues. 

The most comprehensive dataset for Joslyn was developed by the AEC Health and Safety 

Division, based on a survey conducted in January 1952 (Klevin 1952). Only very limited data 

were available for prior years. Operations surveyed included rolling, centerless grinding, cutting, 

and lathe operations. Both breathing zone (BZ) and general area (GA) air samples were 

collected and daily weighted exposures (DWE) were calculated for 19 job descriptions covering 

66 workers. Table 6-1 of the ER presents the range, geometric mean (GM), average, geometric 

standard deviation (GSD), and 95th percentile for each type of operation (to the extent permitted 

by the data). In developing the statistics reported in Table 6-1, NIOSH recalculated all of the 

individual sample results to verify the information in Klevin (1952) and Piccot (1949). This 

resulted in minor adjustments to some samples, so the data in Table 6-1 are not directly traceable 

to the source documents. Rather, the results are traceable to an Excel® spreadsheet (AIR 

CORECTIONS final.xlsm), which was developed by NIOSH from Klevin (1952) and Piccot 

(1949). 

Samples producing less than 1 count per minute (cpm) were treated as non-detects by Klevin 

(1952). However, NIOSH assigned values to these samples, based either on assuming a value of 

1 cpm if no background information was available (e.g., for rolling) or the net value of gross cpm 

minus background cpm if data were available in Klevin 1952 (e.g., centerless grinding). This 

approach is claimant favorable, as compared to treating these values as non-detects. NIOSH also 

calculated the minimum detectable concentration (MDC) for each sample where sufficient data 

were available. Table 2-2 below compares the concentrations calculated by NIOSH for the 

“non-detects” with the MDCs for centerless grinder BZ samples. In general, the values 

calculated for the non-detects were similar to the MDCs, adding credibility to the NIOSH 

approach. 
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Table 2-2. Comparison of MDCs and Calculated Centerless Grinder BZ 

“Non-Detect” Samples 

Sample No. 

(Klevin 1952) 

Calculated Concentration 

(dpm/m3

) 

MDC 

(dpm/m3) 

O406 20 29 

O407 22 27 

O408 52 28 

O411 36 34 

O413 62 21 

O415 12 21 

G191 44 22 

G193 40 23 

G194 15 23 

G195 22 31 

G196 21 30 

G198 54 31 

G199 36 30 

O400 4 31 

However, it is important to note that the units for the data from Klevin (1952) in Table 6-1 of the 

ER are incorrectly stated as pCi/m3 instead of dpm/m3. While this may be a simple typographic 

error, it can significantly distort comparisons with other datasets. 

 

Finding 1: The units of measure for the data from Klevin (1952) in Table 6-1 are cited as 

pCi/m3

, but the presented information is based on dpm/m3. 

Daily weighted exposures for various job descriptions are listed in Table 6-2 of the Joslyn ER. 

These data are not directly traceable to Klevin 1952, but include minor adjustments made by 

NIOSH during recalculation of the Klevin data, as described above. The units in Table 6-2 of 

the ER are also incorrectly stated as pCi/m3. 

Finding 2: The units of measure in Table 6-2 should be dpm/m3, not pCi/m3. 

2.3 URANIUM AIRBORNE LEVELS 

NIOSH notes in Section 7.2.1.1 of the petition ER that: “Battelle-TBD-6000, Appendix B 

utilizes data (Christofano [and Harris], 1960) which were collected starting in 1948 as a 

foundation for its methodologies.” This statement is not correct; Christofano and Harris (1960) 

deal with uranium refining operations, not metal working operations, which are described by 

Harris and Kingsley (1959). Furthermore, Appendix B is not relevant, dealing, as it does, with 

Birdsboro Steel and Foundry. Harris and Kingsley (1959) are silent on the period covered by 

their surveys of metal fabrication operations. However, Christofano and Harris indicate that the 

time period covered by surveys at uranium refining operations was from 1948 through 1958. It 

is reasonable to assume that reported surveys of both uranium refining and metal working 

operations were contemporaneous and both reports shared a common author (W.B. Harris). The 

start date for the metal working surveys is critical, since it establishes the time after which 

NIOSH concludes that bounding dose reconstructions can be performed. This issue needs to be 
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explored further by NIOSH, because it could impact the dates selected for the time period 

covered by the SEC. 

Finding 3: NIOSH should document the basis for assuming that 1948 is the starting date for 

the site surveys upon which TBD-6000 is based. The 1948 date needs to be affirmatively 

established in order to ensure that the TBD-6000 data are claimant favorable. 

2.4 EVALUATION OF BOUNDING RESIDUAL PERIOD INTERNAL DOSES 

In Section 7.2.2 of the ER, NIOSH confirmed from two sources that no residual radioactive 

period was specified. Information in an August 2008 NIOSH document, Report on Residual 

Radioactive and Beryllium Contamination at Atomic Weapons Employer Facilities and 

Beryllium Vendor Facilities, supports the determination that residual contamination at Joslyn is 

not an issue that needs to be addressed (see Attachment A). Based on our review of this 

material, we concur with NIOSH with respect to this matter. 

2.5 METHODS FOR BOUNDING OPERATIONAL PERIOD INTERNAL DOSE AT 

JOSLYN 

Table 7-1 of the ER compares DWEs for Joslyn workers (based on Table 6-2 of the ER) with 

comparable job categories for workers based on Tables 7.3 and 7.5 of TBD-6000 (Battelle 2006). 

For example, according to Table 7.3 of TBD-6000, exposures for a roughing mill operator range 

from 1,620 to 13,700 dpm/m3. This range of exposures is directly traceable to Table 2 of Harris 

and Kingsley (1959). In Table 7.3 of TBD-6000, these values are used to calculate a GM of 

4,710 dpm/m3 (GM = SQRT [1,620 x 13,700]). TBD-6000 further assumes that to convert this 

exposure to a DWA, the GM should be multiplied by an exposure factor of 0.75; thus, the DWA 

is 3,533 dpm/m3

. As stated in Section 7.1.2 of TBD-6000: 

The daily weighted average for the operator’s[sic] is assumed to be the measured 

air concentration for the roughing roll operator, with a 75% weighting factor 

assuming that 25% of the operator’s time was spent away from the high 

concentration. 

Thus, one would expect to see a value of 1,591 pCi/m3

 (3,533 dpm/m3 ÷ 2.22dpm/pCi) as the 

first entry in column 4 of Table 7-1, rather than the listed value of 1,472 pCi/m3. NIOSH 

explained that the value of 1,472 pCi/m3

 was back-calculated from data in TBD-6000 based on 

the assumption of 2,400 hours worked per year. It is our understanding that, for the period 1951 

through 1955, the correct assumption is 2,200 work-hours per year. In addition, as discussed 

above, we believe that the data in column 2 of Table 7-1 are in units of dpm/m3

, not pCi/m3. 

Thus, Table 7-1 is actually not making comparisons in comparable units, and the TBD-6000 

values are understated by about 9%. 

Finding 4: Table 7-1 needs to be corrected to assure that comparable units are used 

throughout, and that 1952 air concentrations from TBD-6000 are based on 2,200 work hours 

per year. 
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NOTICE:

To facilitate our review and make necessary comparisons, Table 2-3 here presents a 

reconstruction of Table 7-1 of the ER, correcting the problems described above.
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Table 2-3. Reconstruction of Table 7-1 of the Petition Evaluation Report 

Joslyn Work Area/Job Description TWA (dpm/m3) TBD-6000 Equivalent Description GM* (dpm/m3) 95% (dpm/m3) AM (dpm/m3) 

18" Rough Roll East 3,322 Rolling Operator 3,533 49,883 12,901 18" Rough Roll West 375 Rolling Operator 3,533 49,883 12,901 Roller Foreman 725 Rolling Supervisor 326 4,603 1,190 Ass't Foreman 725 Rolling Supervisor 326 4,603 1,190 Furnace Heaters 16 Rolling General Labor 651 9,192 2,377 Recorder 16 Rolling General Labor 651 9,192 2,377 12" Rough Roll East 605 Rolling Operator 3,533 49,883 12,901 12" Rough Roll West 570 Rolling Operator 3,533 49,883 12,901 Drag Down (Billet) 310 Rolling General Labor 651 9,192 2,377 9" Finishing Roll East 16,542 Rolling Operator 3,533 49,883 12,901 9" Finishing Roll West 5,791 Rolling Operator 3,533 49,883 12,901 Quench Tank 155 Rolling General Labor 651 9,192 2,377 Draggers 831 Rolling General Labor 651 9,192 2,377 Rod Stamper 242 Rolling General Labor 651 9,192 2,377 Rod Bundler 128 Rolling General Labor 651 9,192 2,377 Lathe Operator 12 Machining Operator 5,480 77,372 20,010 Centerless Grinder 100 Machining Operator 5,480 77,372 20,010 

Grinder (portable) 277 Machining Operator 5,480 77,372 20,010 Cutomatic 191 Machining Operator 5,480 77,372 20,010 

GM* is a DWA value (GM × 0.75) from Tables 7.3 and 7.5 of TBD-6000. AM and 95th percentile calculated from GM* assuming 

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Inspection of the reconstructed table indicates that, for every job description, except 9” Finishing 

Rolling East, the average (or expected value) of the DWA airborne dust loadings associated with 

TBD-6000-equivalent job descriptions is greater than the DWE at Joslyn. The value for the 9” 

Finishing Rolling East lies at the 83rd percentile of the TBD-6000 distribution, so this value 

would be subsumed in a dose reconstruction based on the full TBD-6000 distribution for rolling, 

or would be less than the 95th percentile if a constant value is used in dose reconstruction. 

Table 7-2 of the ER provides a comparison of centerless grinding air concentrations based on 

1951 sampling (Chipman 1943) at Joslyn with equivalent results from TBD-6000. The table 

contains several data entry and typographical errors, including the Table 7-1 Finding discussed 

above. Table 2-4 below presents a reconstruction of Table 7-2 of the ER. This table makes the 

necessary changes and adds comparable Joslyn data from 1952, which allows the reader to also 

make a year-on-year comparison of dust levels from centerless grinding at Joslyn to those in 

TBD-6000. 

 

Finding 5: Typographical and calculational errors in Table 7-2 should be corrected. 

Table 2-4. Reconstruction of Table 7-2 of the Petition Evaluation Report Comparing 

Joslyn Air Concentrations from Centerless Grinding to TBD-6000 Defaults 

Joslyn Work Area/ 

Job Description GM 95% AM TBD-6000 Equivalent Description GM* 95% AM 

Centerless grinding 

1951 BZ (oper.) 944 2,927 1,096 machining operator 1951–1955 5,480 77,372 20,010 

Centerless grinding 

1952 BZ (oper.) 42.4 297 93.6 machining operator 1951–1956 5,480 77,372 20,010 

* This is the GM of DWA values for centerless grinding. The 95th percentile and the arithmetic mean were 

derived from the DWA values for the GM assuming a GSD of 5. 

 

It is important to understand the information in this table in order to judge the degree to which 

TBD-6000 can be used to place a plausible upper bound on the airborne uranium dust 

concentrations that might have been experienced by AWE workers at Joslyn. First, the GM 

values reported for Joslyn for 1951 and 1952 were derived based on taking the GM of the BZ 

samples for personnel performing centerless grinding while they were performing centerless 

grinding. Given these GM values, the 95th percentile values and the arithmetic mean values for 

Joslyn workers were derived assuming a lognormal distribution with a standard deviation of 5. 

The GM mean values reported in Table 2-3 for TBD-6000-equivalent operations are actually the 

GMs of DWAs, not BZ values, as reported in Harris and Kingsley for workers involved in 

centerless grinding operations. It turns out that the term “machining operator,” as employed in 

TBD-6000, is a general term and applies to a broad range of operations, including centerless 

grinding. Inspection of the data reported in Harris and Kingsley (1959) reveals that the data used 

by NIOSH to characterize the dust loading experienced by generic machining operators were 

actually data for centerless grinding operations. This was deliberately done by NIOSH to ensure 

that the exposures to any personnel defined as machining operators are not underestimated. 

From this perspective, NIOSH selected the appropriate TBD-6000 job category for use as a 

bounding surrogate for activities at Joslyn. Given this understanding, the TBD-6000 values are 

GM values of DWAs, while the GM values for Joslyn are for the individual BZ samples. The 

implications are that if one were able to convert the Joslyn BZ values to DWA values, the dust 
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concentrations would be substantially lower, because DWA values include exposures during a 

given work day that occur while the activity is going on (in this case, centerless grinding), and 

also the activity during a given work day when the activity is not going on. Again, the 

implications are that the TBD-6000 values are bounding. 

Section 7.2.4 of the ER states: 

NIOSH concludes that there are site specific data and existing dose 

reconstruction methods available in Battelle-TBD-6000 to support reconstructing 

internal radiation doses with sufficient accuracy for the period from January 1, 

1948 through December 31, 1952.

Based on our review, including reconstruction of key Tables 7-1 and 7-2 above, SC&A concurs 

with this general NIOSH conclusion; however, with certain qualifiers. 

Finding 6: The NIOSH approach for reconstructing internal doses due to metal-working 

operations at Joslyn for 1948 through 1952 appears reasonable for routine operational 

exposures. However, we have concerns that the site profile does not adequately describe how 

the dose reconstruction methods in TBD-6000 are to be applied. In addition, as developed 

further under Finding 8, we have concerns regarding the degree to which the surrogate values 

in TBD-6000 adequately account for exposures associated with outdoor uranium pit burning, 

chip fires, and floor sweeping. 

In its review of other petition ERs, SC&A has concurred with a NIOSH conclusion that a 

bounding calculation can be performed, but has indicated that the approach suggested by NIOSH 

is not appropriate, or that NIOSH did not specify in detail how a bounding approach would be 

conducted. A similar situation exists at Joslyn, where NIOSH states that internal doses can be 

calculated using methods and assumptions in TBD-6000. The logic underlying the NIOSH 

conclusion appears to be based on the following premises and conclusion: 

 TBD-6000 is a vetted document appropriate for use at AWE sites where site-specific data 

are limited or unavailable 

 Air concentration data from Joslyn are lower than data from comparable operations 

characterized in TBD-6000 

 Therefore, TBD-6000 can be used to bound internal exposures at Joslyn 

As described in Section 7.2.3 of the ER, a dose reconstructor would use the GM values from 

Table 7-3 and a GSD of 5 as input into the IREP internal dose calculations. The highest 

observed air concentration at Joslyn is contained within this distribution, as shown above. 

However, as also noted, the available air concentration measurements were made during periods 

of only limited production. Therefore, it is not obvious that use of the full distribution from 

TBD-6000 in reconstructing doses at Joslyn is sufficiently conservative and claimant favorable. 
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Finding 7: To address uncertainty as to whether air concentrations are dependent upon 

production rate, NIOSH should consider using the 95th percentile values from TBD-6000 to 

reconstruct operational doses at Joslyn. 

2.6 DATA ADEQUACY CONCERNS: URANIUM WASTE BURN PITS AT JOSLYN 

MANUFACTURING SITE, CHIP FIRES, AND FLOOR SWEEPING 

2.6.1 Burn Pits 

In the Joslyn SEC ER, NIOSH describes the practice of burning uranium waste in outdoor pits 

onsite during the late 1940s. This information came primarily from U.S. Army Corps of 

Engineers 2005 assessment of the Joslyn site (Army Corps 2005) and from interviews with 

several former Joslyn workers performed in July 2012 (NIOSH 2012b). Section 5.2.1 of the ER 

summarizes the uranium waste burning practices: 

There is evidence that an outdoor area was used to burn waste. According to 

former worker reports, uranium wastes/residues from machining uranium rods 

were collected and dumped on the ground each day and were gone when the 

workers returned the next day. The work experience at Joslyn of these former 

workers began in 1948 and continued beyond the end of covered operations at the 

site. These workers could not give any testimony regarding operations prior to 

1948. These workers related that they learned much later from a co-worker that 

the co-worker was in fact responsible for burning these scraps and wastes at the 

end of the day [NIOSH 2012b]. 

For accountability purposes, efforts were made to collect the residual cuttings 

and dust using steel pans to collect shavings and trimmings and by brushing the 

steel floor plates before, during, and after cutting work. The practice at Joslyn 

was to burn the waste material so that it would be in the less combustible oxide 

form for shipment back to the AEC. NIOSH is aware that former workers report 

that burning operations were performed outdoors by one individual [NIOSH 

2012b]. These former workers reporting on burn operations had work history at 

the site beginning in 1948 through covered operations. 

NIOSH references the Kehoe et al. 1950 report, which discusses the practice of “dry burning” of 

uranium waste: 

The most expeditious and least expensive method for the disposal of uranium 

scraps by conversion to oxide is by direct dry burning in air. For a quantity not 

exceeding 5#, the scrap may be spread out on a steel plate in an open area and 

burned to oxide by the flame of an oxy-acetylene torch. The worker should be 

protected by a welders face shield and a metal fume respirator. The scrap should 

be raked to insure that all the metal goes to oxide. 

NIOSH does mention that waste burning outdoors, as opposed to indoors, does greatly reduce the 

airborne concentrations, as compared to indoor burning, but as indicated in Section 2.6 of this 
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report, even outdoors, these activities could produce substantial airborne dust loadings. In 

addition, it is not known if the individuals responsible for burning the uranium scrap waste wore 

respiratory protection. 

As part of their discussion of the burn pits, NIOSH describes the radiation surveys that were 

performed in the area of the burn pits. In 2004, Radiation Safety Services Incorporated (RSSI) 

took borehole readings in the former burn pit area. Section 4.5 of the ER states: 

This survey included the advancement of soil borings (Borings A - D) in the 

EastWest Bay (Building 8) and in the former burn pit area outside immediately to 

the north of Building 8 (P-l through P-6). Borehole count rates showed elevated 

readings at depths 3-10 ft below ground surface (bgs) in the burn pit area, and at 

depths 4-9 ft bgs in the Processing Building (Building 8). The highest isotopic 

uranium concentrations were in a sample from Borehole D (4-8 ft bgs interval) 

which had uranium-235 at 2.07 pCi/g and uranium-238 at 73.5 pCi/g. Uranium235 was less than 1 pCi/g in the other eight samples for which data were 

reported, and less than 10 pCi/g for uranium-238. [Army Corps 2005] 

SC&A reviewed all of the Joslyn documents referenced by NIOSH in the ER, as well as 

publically available U.S. Army Corps of Engineers documents, and were able to confirm all the 

information presented by NIOSH regarding waste burning activities. SC&A did conduct a query 

of the Joslyn documents on the Site Research Database (SRDB) using the search terms “burn,” 

“burning,” and “burn pit,” but no documents resulted from that query. However, the available 

evidence is sufficient to make a conservative assumption that waste pit burning did occur, as 

indicated by the fact that Army Corps 2005 and Joslyn worker interview report (NIOSH 2012b) 

both discuss the burn pits; both documents are located in the database. Therefore, estimation of 

intakes from exposure at the burn pits is critical. 

Some outdoor burning results were reported for the Melt Plant Building at Hanford in Adley et 

al. 1952. Both an open hearth furnace and a graphite burner were located outside the Melt Plant 

Building. The open hearth furnace was used to burn crucible heels, floor sweepings, used 

gloves, and some material from a chip recovery process conducted in another building. The 

graphite burner was used for burning broken and discarded crucibles and stopper rods. 

Operations associated with a graphite burner produced less dust than operations associated with 

the open hearth furnace. The operation that resulted in the highest dust concentrations was 

shoveling the residue from the open hearth burning into barrels or buckets. In some cases, the 

burned material was sifted through a coarse screen before being loaded into a container. Adley 

et al. (1952) note that while these operations were very dusty, they were of brief duration. They 

characterized the air concentrations for three operations: 

 Operation A – burning in open hearth furnace 

 Operation B – loading oxide from open hearth furnace into buckets and barrels 

 Operation C – graphite burning 

Air sampling results are summarized in Table 2-5 (Adley et al. 1952, Table V), where the GM 

values were calculated using the same procedure used in TBD-6000. 
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Table 2-5. Atmospheric Concentrations of Uranium at Hanford Melt Plant Outdoor 

Burning Operations 

Range of Uranium Concentrations GM Uranium 

Operation Conc. Number of 

Samples 10-5 μg/cm3 dpm/m3 dpm/m3

A 9 1.4 to 260 21 to 3,950 288 

B 3 3,930 to 6,370 59,700 to 96,800 76,000 

C 2 1.4 to 9.8 21 to 149 56 

The measured airborne uranium concentrations for Operation B are significantly higher than any 

of the values from TBD-6000 used in evaluating Joslyn exposures. However, it is difficult to 

make a direct comparison. Table 7.5 of TBD-6000 cites the DWA from centerless grinding of 

uranium to be 5,480 dpm/m3. While Adley et al. (1952) note that Operation B was of “brief 

duration,” it is not possible to estimate what the actual DWA might have been. If the operator’s 

exposure other than shoveling oxide was minimal, then exposure during shoveling would need to 

have not exceeded about 30 minutes per day for a comparable DWA. As discussed below in 

Section 4.0, which summarizes worker interviews, it appears that uranium pit burning was a 

daily occurrence, and exposures from this activity could have been as high as 30 minutes per 

day. 

2.6.2 Chip Fires 

The Joslyn ER mentions the possibility of uranium chip fires: 

The biggest generator of uranium dust associated with machining was probably 

the ignition of small chips and turnings that were generated during machine 

operations ([Battelle 2006], PDF p. 16). At Joslyn, due to the pyrophoric nature 

of the uranium, a heavy flow of coolant was used over the cutting/grinding 

surfaces to minimize sparking. These measures would have also reduced the 

airborne concentrations to some degree. While the rolling operations were 

generally open in the mill buildings, the grinding and cutting operations were to 

be ventilated through the use of a small shed enclosure within the larger building. 

The grinder had an overhead hood connected to a fan and discharge was into the 

inside of the larger shed. During MED/AEC surveys the air concentrations 

around the centerless grinder were still found to be unacceptable and apparently 

this ventilation was not sufficient to meet the standards in effect at the time. 

[NIOSH 2012a, pp. 23–24] 

Beyond the likelihood that chip fires may have been the “biggest generator of uranium dust 

associated with machining,” there is the problem of other chip/turnings fires resulting from 

machining operations; this is discussed in Harris and Kingsley (1959, pp. 111–113). However, 

neither TBD-6000 nor Harris and Kingsley (1959) contain actual data on air dust concentrations 

resulting from such fires. It would appear, therefore, that quantitative data relating to chip fires 

other than routine ignition in the process of machining need to be added to the exposure matrix 

provided in the ER for Joslyn in order for it to be complete. 
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2.6.3 Sweeping 

As mentioned in Section 2.2 above, workers swept up the floors in operational areas every half 

hour. This likely resulted in considerable airborne dust. Neither the Joslyn ER (NIOSH 2012a) 

nor TBD-6000 contain quantitative data on such operations. Harris and Kingsley discuss the 

importance of housekeeping in reducing airborne dust and provide an example of the reduction 

in airborne dust resulting from installation of grating. However, this example is not 

quantitatively relevant to the problem at hand, which would be to estimate airborne dust intakes 

of workers performing the sweeping. This is another item that needs to be added to the intake 

exposure matrix in the ER for it to be complete. 

Finding 8: Though of short duration, the airborne uranium dust levels associated with 

uranium open pit burning and associated activities, such as shoveling the burn residue into 

containers, could contribute significantly to annual intake of uranium. NIOSH needs to 

evaluate the degree to which outdoor open pit burning of uranium shards renders TBD-6000 

incomplete as a surrogate dataset for AWE facilities with limited bioassay and air sampling 

data. NIOSH should do the same for uranium chip fires that may have occurred in the 

machining or scrap storage areas. A third area of concern is that there are no data for the 

frequent sweeping activities that likely generated considerable resuspension of uranium dust. 

The present exposure matrix in the ER is incomplete in all three respects.
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3.0 REVIEW OF METHODS FOR RECONSTRUCTING 

EXTERNAL DOSES 

3.1 EVALUATION OF BOUNDING PROCESS-RELATED EXTERNAL DOSES 

NIOSH states that the information in Table 5-1 of the ER covers 90% of the uranium processed 

at Joslyn. 

Finding 9: It would strengthen the report if the basis for the 90% coverage of the uranium 

source term was documented. 

NIOSH determined that about 1,127,000 lbs of uranium were processed during the covered 

period (from 1943 through 1952). Data supporting this throughput estimate is included in 

Tables 5-1 and 6-3 of the ER. NIOSH further determined that the monthly production rate was 

90 tons, based on a 1948 report (Monthly Report Apr 1948). Using this information, it was 

estimated that uranium rolling at Joslyn occurred over 190 days during the covered period, or 

about 1.6 days per month on average. NIOSH estimated that an additional 95 days were spent 

doing centerless grinding of the uranium rods. Thus, the total time for uranium exposure was 

about 2.5 days per month. Based on this approach, NIOSH concluded that: 

This estimate of exposure duration can be used to calculate external dose from 

uranium metal to workers, using the methods and assumptions in Battelle TBD6000. 

While SC&A believes that it is possible to calculate bounding external doses from uranium 

exposures based on TBD-6000, we have several reservations about the NIOSH approach 

outlined in the previous paragraph. These reservations include: 

 No basis is provided in the ER for assuming 95 days for centerless grinding. 

 It is likely that centerless grinding work would typically be contemporaneous with 

uranium rolling, and it might not be appropriate to add grinding time and rolling time to 

determine total exposure time. This matter should be addressed in the ER. 

 Table 5-1 shows that more than 50% of the total uranium processing occurred in 1948, so 

it is inappropriate to average external exposure over 10 years. Instead, NIOSH should 

consider varying annual external exposures with annual production. 

 The monthly production rate of 90 tons was based on expectations during the time of 

maximum throughput at Joslyn (i.e., March through June 1948). Throughput at other 

times over the 10-year period was much lower. Exposure times during periods of low 

throughput may be higher than predicted from long-term averages. 

Finding 10: SC&A does not agree with some of the assumptions proposed by NIOSH in 

Section 7.3.1 of the ER. SC&A suggests that NIOSH consider prorating the dose values in 

Table 6-4 based on actual working time, such as days per month. At a minimum, the NIOSH 

approach appears to underestimate external exposure in 1948. In addition, there is no need to 
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differentiate between rolling and machining operations, since the doses are the same. 

However there is one caveat—the units of measure for the data listed in Table 6-4 as Metal 

Whole Body Dose should be mrem/yr not mr/yr. This is an important consideration when 

converting whole body dose to organ dose. 

In Section 7.3.1, NIOSH also discusses their ability to reconstruct external doses from thorium. 

NIOSH provides plausible estimates of the mass of thorium processes and the processing 

duration. It is stated in this section that, “NIOSH also has information regarding the radiological 

hazard associated with thorium relative to uranium.” However, the nature of, and references to, 

this information on relative hazards is not provided. 

Finding 11: NIOSH should document the sources of information they propose to use 

regarding the relative radiological hazard from thorium. 

3.2 METHODS FOR BOUNDING OPERATIONAL PERIOD EXTERNAL DOSE AT 

JOSLYN 

Photon Dose

NIOSH states that: 

The monthly exposure duration described in Section 7.3.1 of 2.5 days/month 

provides an annual exposure potential of 30 days/yr for worker exposures. 

As described above, this approach would significantly understate external exposure in 1948 (see 

Finding 10). 

Beta Dose 

NIOSH states that: 

The assumptions, based on annual dose by job category and dose relations as 

described in Battelle-TBD-6000 for estimating beta dose to metal workers will be 

used to bound the dose for the workers at Joslyn by applying the annual exposure 

duration of 30 days/yr as suggest[ed] in the photon subsection above. 

As described above, this approach would significantly understate external exposure in 1948 (see 

Finding 10). 
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4.0 SC&A REVIEW OF JOSLYN PETITION EVALUATION REPORT 

WORKER INTERVIEWS 

A NIOSH team (which included representatives from NIOSH, Advanced Technology and 

Laboratories International, Inc., and Oak Ridge Associated Universities) and SC&A conducted 

an SEC Outreach meeting on July 25, 2012, in Fort Wayne, Indiana, during which [redacted] 

former workers at the Joslyn facility were interviewed (NIOSH 2012b). The [redacted] workers 

all began work at the plant in 1948 or 1949, and one stated working there for 43 years (i.e., 

ending around 1992). Two of the workers had filed claims with the Department of Labor (DOL), 

but had not yet received compensation determinations. 

The interviewers asked about protective equipment and personal radiation monitoring equipment 

provided when the workers handled uranium. The workers recalled that they were only given 

cotton gloves when working with uranium, and that they wore their own street clothes, which 

they were responsible for laundering off-site, at all times in the plant. Although shower facilities 

were provided, they were only used occasionally; in any event, they wore the same clothes home. 

One of the workers described wearing what might have been a type of radiation monitor once at 

the beginning of the worker’s tenure, but none afterwards. No other personal protective or 

monitoring equipment was provided. 

The interviewers asked if the workers could recall any special medical testing related to their 

employment, such as an annual chest x-ray or urinalyses. The workers could only recall an x-ray 

machine being brought onsite for chest x-rays for a short time. 

The interviewers were interested in whether there were radiation sources at Joslyn other than 

associated with the uranium processing, and asked if there were onsite non-destructive test 

facilities, such as those using x-ray instruments, to inspect the uranium. The workers had no 

knowledge of such facilities. 

The workers described the uranium handling and processing in the facility. The uranium was 

first received by rail and placed in a fenced and guarded holding area. Uranium rods were heated 

in batch furnaces, rolled in the rolling mill, sent to the straighteners, and then to the centerless 

grinders (which produced copious sparks and wastes that were collected for later disposal). 

Following that, cutters, which also generated sparks and waste, were used to reduce the length of 

any uranium bars that were too long. Rods were also inspected in an inspection shop. After 

uranium rod processing was finished, the rods were loaded into a closed and guarded railroad 

car, which would then leave the site. Different rolls (in the rolling mill) would be used to 

process uranium or steel. The plant was busy, so there was a lot of overtime, with a typical work 

week of about 48 hours. 

The workers recalled that there were no access controls and people were free to go anywhere in 

the facility. Likewise, there was no employee cafeteria, and workers were free to eat wherever 

they wanted (usually, though, not at their work sites). They were also free to smoke anywhere, 

even at their work stations. 
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The interviewers were particularly interested in dust generation and waste handling and control. 

The workers noted repeatedly that the different processes generated a lot of dust that was inhaled 

and scale and other waste that fell to the floors. They noted that the rolling mill produced a great 

deal of scale and dust that they swept up and put into 5-gallon buckets about every half-hour. 

The buckets were taken outside full at the end of the day and brought back empty the next day. 

Although none of the workers interviewed had ever done so themselves or personally observed 

the activity, they reported that coworkers burned the waste outdoors each night on a steel plate. 

The workers could not recall any other (uncontrolled) fires at the facility. 

The mill floor consisted of steel plates covering a dirt floor and the centerless grinders sat on a 

steel grating (the floor under the grating was swept periodically). The grinders operated with 

liquid coolant running over the uranium and the waste and coolant were collected in bins below 

the grinders. Canvas tents were placed over both the rolling mill and centerless grinders (when 

processing uranium), with air being drawn out into the surrounding buildings. One of the 

workers mentioned that, on cold days, other workers would gather in the centerless grinder tent 

to get warm.
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5.0 USE OF SURROGATE DATA 

Based on the information presented in this report, one can make a determination regarding 

whether or not the use of TBD-6000 surrogate data at Joslyn for routine operational intakes is 

consistent with the surrogate data guidelines developed by the ABRWH (ABRWH 2010). The 

appropriateness of each of the five surrogate criteria are discussed below. 

1. Hierarchy of Data. It should be assumed that the usual hierarchy of data 

would apply to dose reconstructions for that site (Individual worker 

monitoring data followed by co-worker data followed by workplace monitoring 

data such as area sampling followed by process and source term data.) This 

hierarchy should be considered when evaluating the potential use of surrogate 

data. Surrogate data should only be used to replace data if the surrogate data 

have some distinct advantages over the available data and then only after the 

appropriate adjustments have been made to reflect the uncertainty inherent in 

this substitution. 

There were no bioassay data and only limited air sampling data available at Joslyn Steel for the 

1948–1952 period, including a few samples in 1951 and an extensive survey by HASL in 1952 

(NIOSH 2012a, Table 6-1). In terms of hierarchy of data, generic air sampling data from TBD6000 site was substituted for limited air sampling data at Joslyn for the 1948–1952 period. The 

GM and 95th percentiles for the Joslyn rolling date (Klevin 1952) and the TBD-6000 rolling data 

(Battelle 2006, Table 7-3) are compared below: 

Table 5-1. Comparison of Breathing Zone Samples during Rolling 

Source GM (dpm/m3) 95th Percentile 

(dpm/m3

) 

Joslyn 776 22,500 

TBD-6000 4,710 66,500 

Comparison of the two sources indicates that use of the more conservative TBD-6000 data is an 

appropriate adjustment to reflect uncertainties in the surrogate data substitution for rolling. 

Similarly, for centerless grinding, the highest dust loadings at Joslyn were experienced in 1951 

(see Table 2-3 above), while the generic TBD-6000 values are also based on centerless grinding 

as being highest amongst the various operations reported. The Joslyn samples are BZ samples, 

while the TBD-6000 samples are DWA samples. The two sources are compared in Table 5-2. 

Table 5-2. Comparison of Air Samples during Machining 

Source GM (dpm/m3) 95th Percentile 

(dpm/m3

)

Joslyn 944 (BZ) 2,927 (BZ) 

TBD-6000 5,480 (DWA) 77,300 (DWA) 

The generic TBD-6000 values are significantly higher than the measured Joslyn values, 

particularly when considering that the TBD-6000 values are based on DWAs. Comparison of 
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the two sources indicates that use of the more conservative TBD-6000 data is an appropriate 

adjustment to reflect uncertainties in the surrogate data substitution for machining. 

Piccot (1949) can be used to provide added perspective on the applicability of TBD-6000 air 

concentrations to the situation at Joslyn. Piccot reported on a radiation contamination survey 

conducted by HASL in 1949 after major rolling operations had ceased at Joslyn, but little 

decontamination had been done. The highest observed count was 30,000 dpm alpha measured 

with a Zeuto instrument. Since the Zeuto Mark 1, Model 10, Type A instrument had a 100 cm2

window, a measurement of 30,000 dpm is also 30,000 dpm/100 cm2

 or 3E+06 dpm/m2

(http://national-radiation-instrument-catalog.com/new_page_116.htm). Per TBD-6000 

(Section 3.4.2), the surface contamination (dpm (α)/m2

) is equal to the air concentration 

(dpm/m3) times 1944 m.1 Using the GM value of 4,710 dpm/m3 from Table 7.3 of TBD-6000, 

the surface concentration would be 9.17E+06, about three times as high as the highest value 

measured at Joslyn. This provides further support to the reasonableness of using TBD-6000 

rolling data as a surrogate for Joslyn rolling data. 

2. Exclusivity Constraints. In many cases, surrogate data are used to supplement 

the available monitoring data from a site. In those cases, the surrogate data is

[sic] usually used to justify certain assumptions about the distribution or range of 

possible exposures or assumptions about the source terms. In those cases, no 

special justification is necessary beyond the usual scientific evaluation. This is 

akin to the Type II use described above. However, in other situations, there are 

no or very little monitoring data available. In those cases, the use of the 

surrogate data as the basis for individual dose reconstruction would need to be 

stringently justified. This judgment needs to take into account not only the 

amount of surrogate data being relied on relative to data from the site but also 

the quality and completeness of that surrogate data. 

As discussed above, there were limited site data at Joslyn for the period 1948–1952. The fact 

that TBD-6000 has been carefully vetted by a Work Group of the ABRWH is indicative of 

stringent justification of that document as a source of surrogate data. The selected surrogate data 

from TBD-6000 were based on the sampling work of HASL, which is regarded to be of high 

quality. The TBD-6000 data are composites from a number of sites and were selected from the 

source document (Harris and Kingsley 1959) using the most conservative groups of 

measurements. Consequently, the quality and quantity of the data used should satisfy this 

criterion.

3. Site or Process Similarities. One of the key criteria for judging the 

appropriateness of the use of surrogate data would be the similarities between the 

site (or sites) where the data were generated and the site where the surrogate 

data are being utilized. The application of any surrogate data to an individual 

dose reconstruction at a site should include a careful review of the rationale for 

utilizing that source of data. 

 1

 This assumes settling at a terminal velocity of 0.00075 m/s for 30 days. 
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Section 2.1 above presented a comparison of rolling operations at the two sites and showed them 

to be generally similar. Some of the process steps used at Joslyn appear to be less prone to dust 

generation than the generic process described by Harris and Kingsley (1959), upon which TBD6000 is based. However, the issues discussed in Section 2.6 remain: 

(1) It is not apparent that the data supporting TBD-6000 include consideration of open pit 

burning 

(2) The frequency and air dust concentrations due to chip fires need to be addressed 

(3) The intakes from resuspended contamination due to frequent floor sweeping need to be 

estimated 

In view of these three items, it appears that the values for intakes derived from or based on TBD6000 might not be bounding for all workers at Joslyn. 

4. Temporal Considerations. Consideration also needs to be given to the period in 

question, since working conditions and processes varied in different periods. 

Surrogate data should belong in the same general period as the period for which 

doses are sought to be reconstructed unless it can be demonstrated that the 

working conditions, procedures, monitoring methods, and (perhaps) legal 

requirements were comparable to the period in question. 

As discussed under Finding 3, NIOSH needs to document that the TBD-6000 data cover the 

relevant period from 1948 through 1952. The source document (Harris and Kingsley) for the 

TBD-6000 data was published in 1959, but is not clear over what period the data were collected. 

While it is likely that the data are relevant for the 1948–1952 time frame, this point should be 

further investigated. The temporal considerations criterion provides the decision-maker with 

some latitude, noting that surrogate data “should belong in the same general period as the period 

for which doses are sought to be reconstructed.” 

5. Plausibility. The plausibility criterion equates plausibility with the 

reasonableness of the assumptions made regarding surrogate data. The 

plausibility determination should address issues of: 

 Scientific plausibility. Are the assumed models (e.g., bioassay, 

concentration gradients) scientifically appropriate? Have the models 

been validated (where feasible) using actual monitoring data collected in 

a similar situation? 

 Workplace plausibility. Are the assumed processes and procedures 

(including monitoring) plausible for the facility in question? Have all of

the factors that could significantly impact exposure been taken into 

account? Is adequate information available about the facility in order to 

be able to make a fair assessment? 

With regard to scientific plausibility, as described previously, internal exposures were based on 

actual monitoring data collected under similar situations by a respected measurement laboratory. 
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With regard to workplace plausibility, we described in Section 2.1 that the processes and 

procedures that underlie the TBD-6000 data are generally comparable and slightly more 

conservative than the processes at Joslyn. We have also noted that the methodology used in 

TBD-6000 was to select from air concentrations measured for several job descriptions. The 

particular operation (such as rolling or machining) that resulted in the highest exposure was 

employed and applied to all the operators involved in the rolling or machining operation. Given 

this methodology, it is reasonable to assume all of the factors that could significantly impact 

exposure have been taken into account. Adequate information is available about Joslyn to make 

a fair assessment of workplace plausibility. For example, Piccot (1949) provides a detailed 

contemporaneous description of the operations and equipment used at Joslyn. 

It is our opinion that use of surrogate data from TBD-6000 for dose reconstruction at Joslyn 

satisfies the ABRWH criteria for routine operational intakes. However, the three issues 

discussed in Section 2.6 need to be addressed before the intake matrix provided in the ER can be 

considered complete.
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6.0 REFERENCES 

42 CFR Part 83, 2004. Procedures for Designating Classes of Employees as Members of the 

Special Exposure Cohort Under the Energy Employees Occupational Illness Compensation 

Program Act of 2000; Final Rule; May 28, 2004; SRDB Ref ID: 22001. 

ABRWH 2006. Transcript of the 38th Meeting of the Advisory Board on Radiation and Worker 

Health, held at the Marriott Metro Center, Washington, DC, on June 16, 2006. U.S. Department 

of Health and Human Services, Centers for Disease Control and Prevention, National Institute 

for Occupational Safety and Health. 

ABRWH 2010. Criteria for Use of Surrogate Data. Draft. Prepared by ABRWH Work Group 

on Use of Surrogate Data. May 2010. 

Adley, F.E., W.E. Gill, and R.H. Scott, 1952. Study of Atmospheric Contamination in the Melt 

Plant Building, U.S. Atomic Energy Commission Report HW-233352 (Rev.), April 4, 1952. 

Army Corps 2005. Preliminary Assessment Joslyn Manufacturing Site Fort Wayne Indiana; 

U.S. Army Corps of Engineers Buffalo District. August 23, 2005. SRDB Ref ID: 112928. 

Battelle 2006. Site Profiles for Atomic Weapons Employers that Worked Uranium and Thorium 

Metals, Battelle-TBD-6000, PNWD-3738 Rev. 0, Rev. F0; Battelle; December 13, 2006; SRDB 

Ref ID: 30671. 

Chipman, J., 1943. Rolling of Billets Supplied by Union Carbide and Carbon Company, 

correspondence to R.L. Doan from J. Chipman, Joslyn Manufacturing Company. June 30, 1945. 

SRDB Ref ID: 11036, PDF p. 244. 

Christofano, E., and W. Harris, 1960. The Industrial Hygiene of Uranium Refining. Reprinted 

November 1960; SRDB Ref ID: 15774. 

Harris, W.B. and I. Kingsley 1959. The Industrial Hygiene of Uranium Fabrication. American 

Medical Association Archives of Industrial Health, May 1959, Vol. 19, pp. 540–565; SRDB Ref 

ID: 15779. 

Kehoe, E.J., F.I. Brannigan, and M. Eisenbud, 1950. Fire protection precautions for handling 

uranium turnings, chips, borings, sawdust and powder. U.S. Atomic Energy Commission, New 

York Operations Office. March 1, 1950. SRDB Ref ID: 90891. 

Klevin, P.B., 1952. Joslyn Manufacturing and Supply Company Occupational Exposure to 

Radioactive Dust; March 25, 1952; SRDB Ref ID: 9664. 

Monthly Report, Apr 1948. Monthly Status and Progress Report for April 1948; submitted by 

Office of New York Directed Operations; May 5, 1948; SRDB Ref ID 11036. 
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 This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

NOTICE:

NIOSH 2012a. SEC Petition Evaluation Report SEC-00200, Joslyn Manufacturing. National 

Institute for Occupational Safety and Health, Cincinnati, Ohio. December 3, 2012.

NIOSH 2012b. Documented Communication SEC-00200 – Worker Outreach Meeting for Joslyn 

Manufacturing and Supply – Unredacted Draft Minutes. July 25, 2012, 09:45 am. 

SRDB Ref ID: 118494. 

ORAUT 2011. Guidance on Assigning Occupational X-ray Dose Under EEOICPA for X-Rays 

Administered Off Site, ORAUT-OTIB-0079, Rev. 00; Oak Ridge Associated Universities Team, 

Cincinnati, Ohio. January 3, 2011; SRDB Ref ID: 89563

Piccot, A.R., 1949. Residual Contamination Survey at Joslyn Steel Co.; August 22, 1949, SRDB 

Ref ID: 11036, PDF pp. 46–50; SRDB Ref ID: 9663, PDF pp. 6–14. 

SC&A 2006a. Report to the Working Group on Special Exposure Cohort Petition Review, Draft. 

SC&A, Inc., McLean, Virginia. January 16, 2006. 

SC&A 2006b. Board Procedures for Review of Special Exposure Cohort Petitions and Petition 

Evaluation Reports, SCA-TR-TASK5-0002, Rev. 1. SC&A, Inc., McLean, Virginia. June 12, 

2006. 
Effective Date: 

 March 28, 2013 

Revision No. 

 0 – DRAFT 

Document No. 

SCA-TR-SEC 2013-0069 

Page No. 

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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

ATTACHMENT A: RESIDUAL RADIOACTIVITY EVALUATIONS FOR 

INDIVIDUAL FACILITIES 

FACILITY NAME: Joslyn Manufacturing and Supply Co. 

Ft. Wayne, Indiana 

ALSO KNOWN AS: Joslyn Stainless Steel Co. 

TIME PERIOD: 1944–1952 

FACILITY DESCRIPTION: DOE Office of Health, Safety and Security Website: 

Joslyn rolled uranium rods from billets for use by the MED and the AEC in weapons production.

DISCUSSION: 

The billets were received by rail. Work was conducted under MED/AEC constant supervision, 

and scraps and ash generated were retained by MED/AEC personnel for uranium accountability. 

Small furnaces were used to heat the material. Three mills and straightening, cutting, threading, 

and grinding equipment were used in the operation. An outdoor area was used to burn waste. 

Documentation reviewed indicates that there was a comprehensive radiological survey 

performed at the end of AEC activities (1949), for the purpose of identifying contamination 

levels for a facility cleanup. While no post-decontamination surveys are available for review, 

description of the removal of equipment and handling of accountable materials at the end of the 

operations, in conjunction with the conditions identified in subsequent DOE preliminary 

FUSRAP surveys (1976) indicates that residual contamination did not exist beyond the listed 

period. 

INFORMATIONAL SOURCES: 

The sources of information reviewed included: 

 

 DOE Office of Health, Safety and Security Website 

 Residual Contamination Survey at Joslyn Steel, August 22, 1949 

 DOE Report (ORNL); Preliminary Survey of Joslyn Stainless Steel Company, Fort 

Wayne, Indiana; March 1980 

 ERDA Memorandum; Thornton to Kennedy; Subject: ERDA Resurvey Program: Joslyn 

Stainless Steel Company, Fort Wayne, Indiana; March 10, 1977. 

EVALUATION FINDINGS: 

Documentation reviewed indicates that there is little potential for significant residual 

contamination outside of the period in which weapons-related production occurred.